BG/BG: Biodiversity and geodiversity

Support for doubling nature in South Cambs. However quite vague, unless specific percentages by each parish are produced as a starting point-a clearer target in Cambs City.

Beware of BNG being used in such a way that ineffective compensation is made for irreplaceable loss of biodiversity and associated public amenity local to the development

Current policy provides rather "fuzzy" protection of designated nature conservation sites from impacts of development on adjacent land. We need much more objective policy components including buffer zones of set depth from designated site boundaries within which no development is allowed, irrespective of the ownership of the land

Biodiversity net gain calculations can easily be fudged and unscrupulous "professional" ecologists appear to be following wishes of applicants at cost of scientific process

The commitment to 20% BNG is excellent. However, I have three concerns: baseline survey work will need to be sufficiently detailed and thorough to allow rigorous assessment both of potential and actual net gain or loss; ‘contributions towards off-site, larger scale projects’ may offer an easy opt out for landowners and developers; and the policy does not mention that 'scarce and protected species are likely to need separate consideration to the biodiversity metric'. The attached paper suggests ways of remedying these shortcomings.

The 20% biodiversity net gain on development sites is a good goal but nowhere close to “doubling nature.” Biodiversity gain has to be realistically evaluated and then monitored. Just putting up bat boxes is not sufficient if green space has been concreted over – bats won’t stay, whether or not boxes are provided.

The Wildlife Trust strongly supports this policy along the lines proposed, including the proposed 20% BNG and the recognition of the need to address recreational impacts on SSSIs and other natural greenspace sites.

Executive summary

The proposed policy is to achieve a 20% Net Gain in Biodiversity with a focus on the use of the Defra metric. However, species specific measures including nest boxes for cavity-nesting bird species, such as swifts, which are Red Listed and in significant decline, do not count in the Defra metric. Government guidance in the NPPG and the National Model Design Code, as well as several authorities, including RIBA and NHBC, support the installation of nest boxes in new developments as a low cost and effective way of achieving biodiversity gain (detailed references below).
As nest bricks are not included in the DEFRA BNG metric, they need to be included in the policy. We strongly suggest that the ‘Biodiversity and geodiversity’ Policy in the new Local Plan should include some specific wording to reference what other measures, including those for species inhabiting the built environment, will be used to assess biodiversity gain – mentioning swift boxes and bat boxes, as in the text of the ‘GC LP First Proposals’ document:
‘Nest boxes designed for swifts will also be suitable for starlings, house sparrows and tits, and will provide a low-cost way of achieving significant net gain in biodiversity’
At least a 1:1 ratio of nest bricks to dwellings is generally accepted now as good practice, with separate provision for bats depending on the characteristics of the site.

Biodiversity net gain

We have concerns that with the focus on the Defra metric for calculating biodiversity net gain, which is based only on green habitats, there is a danger that important biodiversity opportunities for species with measures such as nest bricks, roosting bricks, hedgehog highways etc may be given less emphasis or be overlooked completely. It is not clear in the ‘Policy Direction’ of the ‘Biodiversity and geodiversity’ part of the First Proposals’ document how such species measures are to be taken account of alongside the results of the Defra metric in assessing overall net gain in biodiversity. Given that much of the development in Greater Cambridge is in more ‘urban areas’ either within Cambridge City or new towns such as Northstowe then we believe these urban species are an important part of bringing nature close to people and an effective way of helping our declining wildlife.
We welcome the recognition of this in the text of the ‘GC LP First Proposals’ document on page 169 under the heading ‘Why is this policy needed’:
‘The focus for biodiversity enhancements is intended to be within the boundary of a site, and could include providing wildlife areas, trees, or smaller measures such as including bat or swift boxes’
Government guidance

The significance of species-specific measures in biodiversity net gain is emphasised by Government Guidance on the NPPF issued on 21 July 2019 (see below):
https://www.gov.uk/government/news/brokenshire-orders-house-builders-to-protect-wildlife
https://www.gov.uk/guidance/natural-environment
Paragraph 23 of this Guidance headed 'How can biodiversity net gain be achieved?' includes at the end of the first sub paragraph 'Relatively small features can often achieve important benefits for wildlife, such as incorporating swift bricks and bat boxes in developments and providing safe routes for hedgehogs between different areas of habitat.'

The recently published National Model Design Code: part 2 - guidance notes (20/07/21) also makes reference to bat and bird boxes and bird bricks. In Section N.3 Biodiversity, page 25: "Integrating Habitats: Biodiversity can be enhanced through facilitating habitats and routes for wildlife, for example, incorporating trees, wildflowers, ponds, bat and bird boxes, bee and bird bricks and hedgehog highways."

https://www.gov.uk/government/publications/national-model-design-code

The case for nest boxes

Swifts in the UK are on the Birds of Conservation Concern (BoCC) Red List and are classified as Endangered on the IUCN Red List assessment of extinction risk for Great Britain. Their numbers declined by 58% between 1995 and 2018, and by 41% in just 10 years up to 2018, that is over 5% per annum! Sparrows and starlings are also Red Listed in the UK.

The decline of birds such as swifts, which have nested for generations in older houses in holes and cavities under the eaves and in walls, is highlighted in a recent report – the Environment Agency, Chief Scientists Group (2021) The state of the environment: the urban environment:

The state of the environment: the urban environment - GOV.UK (www.gov.uk)

Loss of nest sites in older buildings is thought to be a significant factor in their decline and many new houses have been built with no new nest sites incorporated. Bird and bat boxes are relatively cheap, easy to integrate into new builds (generally as swift or bat bricks) and are sustainable needing no ongoing maintenance. Also, swift bricks successfully cater for other bird species such as house sparrow, starling, blue tit, great tit and house martin and can be considered as a ‘universal nest brick’, in numbers equal to the number of dwellings, as noted in:

https://cieem.net/swift-bricks-the-universal-nest-brick-by-dick-newell/

Support for incorporation of nest boxes in new developments
The Royal Institute of British Architects (RIBA) in: Gunnell, K., Murphy, B. and Williams, C., Designing for Biodiversity: A technical guide for new and existing buildings, RIBA Publishing & Bat Conservation Trust (2013).
An excellent recent report produced by the NHBC Foundation from a collaboration between the RSPB and Barratt Developments gives significant guidance on these issues on page 42 onwards, which includes providing nest sites (nest bricks) at a ratio of one per dwelling.
NHBC Foundation, Report NF 89, ‘Biodiversity in new housing developments: creating wildlife-friendly communities’ (April 2021). Available at:
Biodiversity in new housing developments: creating wildlife-friendly communities - NHBC Foundation
An expected new British Standard, BS 42021, ‘Biodiversity and the built environment: Specification for the Design and Installation of Bird Boxes’ is expected to give box/brick specification and a level of installation in new builds in line with current good practice.
(Proposed publication start date 07/02/22)
https://standardsdevelopment.bsigroup.com/projects/2017-03102#/section

Current good practice for nest boxes – Planning Authorities

The 1:1 ratio of nest bricks to dwellings was first outlined in the award-winning Exeter City Council Residential Design Guide SPD (2010). A number of planning authorities have adopted similar guidelines – for example Oxford, Cornwall, Brighton and Plymouth and South West Devon.

Within the OxCam Arc, Oxford City Council are leading the way with guidance on this issue. The recent Oxford City Council Technical Advice Note 8 entitled ‘Biodiversity – Planning Application Guidance’ gives an ‘expected provision’ of bird nest sites for building dependent birds’ at a rate of 1 per house and 1 per 2 flats, with separate provision for ‘bat roost sites’ at a rate of 1 per 5 houses and 1 per 10 flats.

https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan

Case studies
The Duchy of Cornwall adopted the same principle of one nest site per dwelling in 2015, and a good example of the provision of a general type of integral box for all cavity nesting birds is the Nansledan development in Newquay:

https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/

Our own local projects with developers (e.g., Taylor Wimpey and Hopkins Homes) at Northstowe, Cambourne West, Melbourn and elsewhere indicate an increasing willingness to engage with integral nest box projects already acknowledged in 2021 by clear environment strategies:
https://www.taylorwimpey.co.uk/corporate/sustainability/environment-strategy
Significant success has already been achieved in Cambridge and surrounding villages with substantial new swift and sparrow colonies established.
An example from Poland also demonstrates the effectiveness of nest boxes:
https://link.springer.com/content/pdf/10.1007/s10531-021-02334-0.pdf

In conclusion
We strongly suggest that the ‘Biodiversity and geodiversity’ Policy in the new Local Plan should include some specific wording to reference what other measures, including those for species inhabiting the built environment, will be used to assess biodiversity gain – mentioning swift boxes and bat boxes, as in the text of the ‘GC LP First Proposals’ document.
Submitted on behalf of:
Action for Swifts; Fulbourn Swifts; Over and Swavesey Swift Conservation Project 2020

strengthen.. The policy .. adversely affecting ..importance... will NOT be permitted.

Adjoining designated nature sites, must be included in developer BNG site assessments.
Nature is not confined to site boundaries on maps.
Exceptions will ..public benefits significantly and overwhelmingly outweigh any adverse impacts and there is agreement by the custodians of any external site affected.
In such cases where development is permitted, biodiversity, tranquillity, light, air, noise, amenity must measure 20% BNG across all affected sites.

Any realistic meaningful mitigation measures must be based on professionally accredited independent reports.

Acceptable new development must have buffering green corridors to double nature

Objection is made to the requirement for development to achieve a minimum 20% biodiversity net gain as this is considered too onerous and not achievable in all cases. The Environment Bill introduces a mandatory 10% minimum biodiversity net gain and it is considered that Greater Cambridge should not seek to double this requirement on all development sites.

Objection is made to the requirement for development to achieve a minimum 20% biodiversity net gain as this is considered too onerous and not achievable in all cases. The Environment Bill introduces a mandatory 10% minimum biodiversity net gain and it is considered that Greater Cambridge should not seek to double this requirement on all development sites.

Biodiversity of designated sites does not stand in isolation; surrounding land forms part of and supports the biodiversity of a designated sites

Where development is proposed in proximity to a designated site, policy needs to require evidence based BNG and funded management regimes for the proposed development site, the designated site and the wider biodiversity area
v) 'Offset site compensation for loss of environmentally designated open space must recognise that replacement is not like for like and is liable to deliver net loss of biodiversity if new ecosystems are substituted for established ones and green networks are interrupted.

PEAs and BNG / mitigation proposals need to be the subject of accredited specifications and subject of independent accredited QA.

Development management
Development proposals in proximity to designated sites needs to the subject of:
- Early pre application discussions with representatives of the designated site
- Early site visits to enable all parties to be made fully aware of the site's specific characteristics and relevant policy protection and requirements
Registration address. Change so that wildlife sites and Open spaces can be registered in name as neighbourhood sites. At moment – Open spaces cannot be formally registered on neighbour notification list.

PEA Desk top studies must be within 1 years date of application with up to date records from a County Ecological Records database and cover on-site and meaningful off-site records within a 1 km radius.

Buffering. Promote principle of garden buffering or land buffering to protecting designated wildlife sites. Set a standard of 30-50 metres to consider protecting wildlife or other protected habitats or enhancing beyond the site.

The principle of Policy BG/BG is supported, and it is also supported that the Councils have taken a proactive step to identifying habitat sites that smaller developments can contribute towards nature conservation programmes and projects.

However, the proposed policy sets a higher bar at 20% than the legal requirement of 10%, with the justification that the minimum legal requirement would not bring such great benefits for biodiversity. Further consideration needs to be given to the viability of schemes and deliverability of third level of ecology improvements to achieve the required level of 20%. The implications of this increased level of biodiversity net gain would potentially be to restrict small, medium, and large forms of development from coming forward in a timely manner.

Further consideration should be given too proposing a biodiversity net gain that meets the legal requirements of 10%.

There is no evidence justifying the need for 20% BNG onsite and why there should be a higher requirement than what is set out in the Environment Act. The viability assessment does not consider the great impact on the deliverability of some sites and could prevent many sites coming forward for development. The policy should be in line with the national legislation with 10% net gain.

Huntingdonshire District Council have no comment.

The proposed direction and wording of local policy should therefore be revised to match national policy, simply citing that the Secretary of State preferred metric and value will be used when measured biodiversity gains rather than specifying a specific metric within local policy.

This policy is being contravened by allowing an industrial scale development on the Green Belt at Honey Hill. This development will have 20 metre towers and much of the plant will be lit 24/7 causing disturbance to wildlife. Habitat will be destroyed by construction traffic and disturbance, including rare insects at the site. There is a serious contamination risk to Quy Fen SSSI which is being minimised by the developer. Flood risk is increasing with climate change and this is also being minimised. BNG is totally meaningless. The Wicken Fen Vision will be compromised.

It appears that this policy will be more specific and onerous than OS21, so there would be an additional cost to compliance which the councils should carefully consider, both in terms of the cost to the public purse and the knock-on effect on requests for developer contributions to reflect the higher cost of education provision.

There may be opportunities for strategic planning of biodiversity net gain on existing education sites, to facilitate new school development and also new housing elsewhere in the Greater Cambridge area. We recommend that you work with Cambridgeshire County Council, further/higher education providers and other partners to explore how the education estate might deliver biodiversity net gain and support sustainable development.

Any plan which does not include Honey Hill is a fake plan. Please tell the truth.

I have not found any specific mention of ponds. These can have a significant beneficial effect on biodiversity.
Enhancement of the infrastructure for wildlife, such as (as suggested) trees, bat boxes and swift boxes, is good, but measurement of any gain should also take into account adverse effects of general disturbance, noise, light and domestic animals, particularly cats.

Preserving and enhancing biodiversity and green space is important for health and wellbeing, as well as carbon sequestration. It also makes the region a pleasant place to live, and hence benefits the local economy.

We are grateful to see that the importance of geodiversity has been noted in the documents:- We are responsible for having designated Local Geological Site in the county: in general LGS should have the same protection and force as Local Wildlife Sites.
There are a number of Geological Sites (SSSI and LGS) within the area

Using the words "Where Possible" says to me you are not serious about this and gives potential developers the option to not do it as it does not say "Must". If you are using the words Where Possible, it suggests you are not serious about the point.

The Plan should require that even if a BNG of 20% is demonstrated, development will not be permitted if any nationally or locally (eg named by Cambridgeshire and Peterborough Biodiversity Group) designated species of concern will suffer loss of habitat or population impairment unless credible alternative habitat provided, translocations undertaken if appropriate and funding secured for long-term protection & site maintenance is secured.
(There are legitimate concerns that application of the Defra Biodiversity Metric 3.0 has flaws and so should not be sole metric used.)

The policy should in addition provide for establishing areas of "Important Natural Habitats" covering areas locally identified for wildlife / biodiversity value, which do not currently enjoy designated status (Local Nature Reserve up to Ramsar sites). This would help proactively inform development decisions thereby avoiding introducing cost and delay when proposals are met with objections based on a site's high wildlife value.
The requirements for designating Important Natural Habitats would need to be tightly defined. The designation would complement but not conflict with designations under policy BG/PO Protecting open spaces.

4.32. MGH is supportive of the Policies in this section of the First Proposals consultation, and of the proposed policy direction under Policy BG/BG: Biodiversity and geodiversity.
4.33. New development provides significant opportunities for improvements to the natural environment, particularly at strategic development sites that provide greater scale to make changes. At such new developments of scale it is possible to target specific biodiversity issues, and provide well planned green infrastructure that relates to and enhances existing natural features. The Local Plan policies should require net biodiversity gains on-site to be fully explored and provided. Urban extensions will allow green infrastructure to reach into urban areas, providing an extended green space network for both existing and new employees and residents.
4.34. In carrying out biodiversity assessments, value should be placed on the longevity of new communities such as that being proposed at North Cambourne, and new natural habitats associated with them. These habitats are designed to be retained in perpetuity. Existing trees and hedgerows may be given high biodiversity value because of their longevity, but it should also be recognised that older trees will eventually die. New environmental features and natural habitats can have significant ecological value as they mature over a period of decades following construction.

This policy this is the most controversial element of the “Biodiversity and green spaces” portion of the Local Plan.
While I, like so many others, am of course in favour of increasing biodiversity in Greater Cambridge, there are a lot of questions around the measurement of biodiversity net gain, the imprecision of the indicator, and, most troubling, the option to use off-site contributions to increase net gain. Indeed, I am surprised that the “First Conversation consultation” showed “very strong support for biodiversity net gain including use of off-site contributions” – I believe that there was strong support for biodiversity net gain but would question if there is truly ‘strong support’ for off site contributions.
I think the policy should also be clearer that the Plan’s biodiversity objectives are about controlling development impacts, and not about improving biodiversity on existing sites (even a goal of ‘no net loss’ would be something, and given that biodiversity has been degraded across the country in recent decades, seeing some goals for increased biodiversity on existing sites would be welcome). The 20% gain is only being sought if nature is damaged as part of development on new sites. The policy says that it will “seek wider environmental net gains” so perhaps there are greater ambitions, but this should be spelled out. The current policy only addresses space impacted by development and seems like a missed opportunity to set goals for increasing biodiversity overall.
On new development sites, developers will of course seek to show either that there is no net loss (or if this is impossible, to mitigate offsite), and the methodology – using DEFRA’s new BNG (biodiversity net gain) calculator 3.0 for determining damage to a site seems weighted in developer favour.
While I appreciate that biodiversity is very difficult to measure, especially for use in a regulatory/market framework, new DEFRA’s BNG 3.0 algorithm seems excessively simplistic, looking only at habitat features and excluding species measurement (I understand that habitat is seen as a proxy for species). The metrics used to calculate ‘biodiversity units’ – there are only four – of size, distinctiveness, condition, and strategic habitat are very subjective and are measured in a difficult-to-understand way – why is distinctiveness measured along a scale of 0 – 8, while condition is on a scale of 1 -3, and strategic significance is 1 – 1.15 (this last on a scale which seems incapable of capturing any real difference). Moreover, DEFRA 3.0 (unlike 2.0) explicitly excludes the metric of “connectivity,” and this is at odds with the corridors and connectivity themes of both the Green Infrastructure policy (BG/GI) and the River Corridors policy (BG/RC). Developers will hire ‘environmental consultancies’ to gauge these metrics, which are likely to come in at the low end, given the complicity between these consultancies and the developer industry.
Where developers are not able to provide 20% net biodiversity gain onsite, they are allowed to make contributions to off-site projects. This provides no advantage for residents of the local area either in terms of biodiversity or connectivity, and it is questionable whether at the nationwide level biodiversity benefits would be delivered, as it is entirely possible that sites with a lower base line biodiversity elsewhere could be chosen for the mitigation efforts.

I support John Meed’s suggestions for strengthening the objectives of this policy (see attached)

Biodiversity protection is not achieved just by a site boundary drawn on a map. Policies need to recognised that surrounding areas eg provided by surrounding gardens which depending on size can act as buffer zones and green corridors and their surroundings, are all material to protection of bio diversity..

The objective to ‘Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before’ is most important. Policies must provide for the protection and enhancement of existing green spaces and corridors, in more urban areas especially where they are adjacent to areas of major development. Developers always seek to underplay the negative impacts of development such as the loss of open space, the effects of hard surfaces etc. Increasing green spaces for people is a necessary counter.